UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Ventura County Air Pollution Control District Rule 74.1 5 .1 Boilers, Steam Generators, and Process Heaters

Prepared by: Nicole Law

February 2014 2



Agency: Ventura County Air Pollution Control District ( VCAPCD )

SIP Approved Rule: Rule 74.1 5 .1

– Boilers, Steam Generators, and

Process Heaters

Adopted /Amended

– June 13, 2000

Submitted

– December 11, 2000 EPA Approved

– October 10, 2001 ( 66 FR 51576 )

Superseded Submittals: none

Subject of this TSD: Rule 74.1 5 .1

– Boilers, Steam Generators, and

Process Heaters

Amended

– September 11 , 2012

Submitted

– April 22, 2013

RULE SUMMARY

- Rule 74.1 5 .1 regulates emissions of oxides of nitrogen (NOx) and carbon monoxide (CO) from boilers, steam generators, and process heaters

. Changes from the approved SIP rule include:

1. Added a section to B. Requirements for units with rated heat input capacity equal to or greater than 1,000,000 BTU/hr and less than or equal to 2,000,000 BTU/hr. The limits associated with these units are 20 ppmv for emissions of oxides of nitrogen and 400 ppmv for emissions of carbon

monoxide. This new section also requires that the devices be certified in accordance with South Coast Air Quality Management District Rule 1146.2.

2. Moved the requirement that units u nder section B.1 be tested for compliance every 24 months to a new section B.4.a.

3. Added sections for testi ng requirements. Section B.4.b describes testing requirements for unit s with a rated heat input capacity less than or equal to

2 million BTU/hr and section B.4.c describes annual screening requirements.

4. Revised Section D.2 to require the tune

- up reports be submitted within 45 days instead of 12 months.

5. A dded section D.3 requiring the annual scree ning reports from section

B.4.c be submitted annually.

6. Added section E.4 describing screening analyses requirements.

7. Added section F.4 describing how a violation is determined using screening analysis and what reporting and corrections need to be made.

8. Added definition s for “ alternate fuel” and “new boiler, steam generator, or process heater” in section G. 3



EVALUATION CRITERIA

- The following criteria were used to evaluate the

submitted rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

- EPA ’ s Alternative Control Technique Document ( ACT ) titled,

“ NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers ” (EPA

45 3 / R

- 94

- 022, March 1994 ), CARB ’ s RACT/BARCT guidance titled,

“ Industrial, Institutional, and Commercial Boilers, Steam Generators, and

Process Heaters ” (July 18, 1991), and other state and local rules for this category were used to help evaluate stringency. Generally, SIP rules are

evaluated for RACT requirements of CAA § 182(b)(2) and § 182(f).

3. SIP Relaxation

- CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modifi cation of any SIP

approved control requirement in effect before November 15, 1990, in a

nonattainment area.

EPA EVALUATION

- A summary of our evaluation of the three criteria follows.

1. The rule requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficient ly ensure that affected sources and regulators can evaluate and determine compliance

with Rule 74.1 5 .1 consistently.

2. The submitted rule is as stringent as other California Distri ct rules for this
category , including South Coast AQMD Rule 1146. 1 and Sacramento Metropolitan AQMD Rule 41 1 and it is more stringent than CARB ’s RACT/BARCT guidance . As a result, we have determined that this rule

fulfills stringency requirements. Rule 74.15.1 is not subject RACT since the rule is applicable to sources too small to exceed the major source threshold and there is no CTG for the source category.

3. W e propose to determine that our approval of the submittal would comply

with CAA §§ 110(l) a nd 193 because (1) the proposed SIP revision would

not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the emission limits in the submitted rule are more stringent than the existing SI P

- approved control requirements that they would replace. 4



RULE DEFICIENCIES

– We have identified no deficiencies with Rule 74.1 5 .1 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– The following revisions are not currently the basis for rule disapproval, but are

recommended for the next time the rule is amended

.

1. South Coast AQMD Rule 1146.1 has lower NOx emission limits for

units fired on natural gas in section (c)(2) Table 1146.1

- 1 ; consider

the se lower limits the next time the rule is amended.

EPA ACTION

- The submitted Rule 74.1 5 .1 strengthens the SI P. The rule largely

fulfills the relevant CAA § 110 and part D requirements

. EPA staff recommends a

full approval of Rule 74.1 5 .1 pursuant to CAA § 110(k)(3) and § 301(a).

REFERENCES

-

1. VCAPCD Rule 74.1 5 .1

, Boilers, Steam Generators, and Process Heaters

, as amended June 26, 2012 and submitted to EPA on April 22, 2013

. 2. VCAPCD Rule 74.15.1

, Boilers, Steam Generators, and Process Heaters

, as amended on June 13, 2000 , and approved into the SIP on October 10,

2001 ( 66 FR 51576 )

. 3

. “NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers,”

EPA

- 45 3 / R

- 94

- 022, March 1994. http://www.epa.gov/glo/SIPToolkit/ctg_act/199403_nox_epa453_r

- 94

- 022_ici_boilers.pdf

4

. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations, ” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988

. 5

. “ Guidance Document for Correcting Common VO C & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, Augu st 21, 2001 (http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf ).

6

. “ Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technolog y for Industrial , Institutional, and Commercial Boilers, Steam Generators, and Process Heaters

, ” CARB, July
18, 1991 http://www.arb.ca.gov/ractbarc/boilers.pdf

.